PLR 9232030 & Sec. 1031 Exchanges

One of the most fascinating things about Section 1031 tax law is that relatively few cases have been resolved in court. Most of the opinions shaping the mechanics of Section 1031 exchanges, including PLR 9232030, come from non-authoritative sources, such as Revenue Procedures and Private Letter Rulings directly from the IRS. Documents from the IRS […] SEC Settlement SEC Settlement Matters

In recent articles, we’ve touched on initial coin offerings (ICOs). We’ve seen how the SEC has had to reprimand certain companies due to various ICO missteps made by digital asset companies. For instance, we recently looked at the case of Munchee, Inc., and discussed the specifics of the federal crackdown on Munchee’s proprietary digital coin. […]

SEC Cryptocurrency

SEC Cryptocurrency Involvement

On our blog, we’ve covered quite a few issues related to cryptocurrency taxation and tax collection lately. What we haven’t talked about yet is initial coin offerings. Initial coin offerings, or ICOs, are similar to initial public offerings, which occur when a private company becomes publicly traded. We’ve seen multiple initial coin offerings in the […]


FATCA Compliance Requirements

Back in 2010, former President Barack Obama signed into law the HIRE Act in an effort to accelerate recovery from the 2008 financial crisis. The HIRE act – short for Hiring Incentives to Restore Employment – endorsed the Foreign Account Tax Compliance Act (FATCA) at the time it was passed. FATCA is a highly significant […]

Private Tax Collectors

Private Tax Collectors in IRS Debt Collection

The Internal Revenue Service has recently started a new collection program. Specifically, it has begun engaging in the practice of assigning tax debt accounts to private collection firms. This practice will change the game for debtors in a lot of ways. For one thing, private tax collectors will now be directly contacting tax debtors for […]

EB5 Visa fraud

Feds Crack Down on EB-5 Visa Fraud

The United States is becoming a cosmopolitan country. This is more true today than at any other point in history. We can find various pieces of evidence confirming this case. We can see this in the proportion of our foreign born population. Other evidence is the increasing number of foreign investors seeking U.S. residence. The […]

Cryptocurrency Tax

Cryptocurrency Tax Advice

Cryptocurrency tax debt collection is here to stay. This has been made very clear by recent statements of the IRS. The IRS has already put a great deal of effort toward backing up its stated intention to enforce tax laws on cryptocurrency gains. We’ve seen an example of this with the 10,000+ letters sent out […]

Cryptocurrency Personal Property Exchanges

Cryptocurrency Personal Property Exchanges Pre-TCJA

We’ve been discussing virtual currency, cryptocurrencies, and digital currency quite a bit lately here. That’s by design. They’ve all been in the media a lot lately. That’s largely due to the increased tax collection efforts by the IRS. Many bitcoin holders started out with the impression that they were “outside the system”. Despite those impressions, […]

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